Three Sensible Safety Trends We Would Like To See

1. Reforming Safety Requirements That Kill More Than They Save
For decades, SOLAS regulations have mandated On-Load, Release, Retrieval Systems (OLRRS) for lifeboats, whose complicated and non-transparent name conveys the functionality of these complicated and non-transparent contraptions, which habitually kill innocent seamen. Back in the ’80s, some desk bound marine safety officials cooked up a requirement that lifeboat davit wire hooks had to be able to release a boat full of people when the weight of the boat was still on the davit wires. While it is possible to imagine a rare circumstance when such a capability may be useful, the large number of seamen who have died while testing these clunky and hard to use devices proves that they are useless.
If anyone knows of a case where OLRRS devices have saved lives, please let us know. SOLAS and IMO admit there is a problem insofar as their faceless committees keep issuing “updated circulars”, such as Marine Safety Committee-1’s 2011 update number 1392, which itself is like the deadly devices themselves, clunky and hard to understand.

Dysfunctional lifeboat OLRRS devices are not the only example, but Fast Rescue Craft (FRC), mandated on certain classes of passenger vessels since the Estonia ferry disaster in 1994 is another. An IMO committee thinks that a fragile FRC could be of use in picking up man overboard victims, when in fact, rough seas recovery via davit of small craft, is a death trap for unwitting users. Worse, FRC rules mandate davit launching capability under conditions of no ship’s power, which has introduced some of the most complicated and nontransparent hydraulic systems known to man. Systems which are far outside the ability of ordinary crewmen to understand or fix in the case of malfunction.

2. Safety Rules Need To Consider The Mechanics Of Human Accidents

Physical factors (e.g. defective or badly designed equipment) combined with human shortcomings (e.g. too-high workload, boredom or fatigue) cause injuries. Both need to be understood within the context of probable risk. Too many safety rules are created with insufficient regard to the context in which humans perform work.

For example, in the case of those compulsory FRBs, more than once during Class Surveys, I have seen crewmen brush death in FRB recovery operations being made by vessels tied up to the wharf on sunny days in sheltered harbors. Therefore any future Sensible Safety User Committee should personally invite those individual members of the SOLAS IMO, who endorse compulsory Fast Rescue Boats on large passenger vessels, to come on board and personally show us how to launch and recover an FRB from the deck of an Estonia-like Baltic Sea ferry at night in a winter storm.

There is the larger topic of HMI – Human Machine Interface, (ergonomics) much of which is also swept under the carpet. Imagine if cars had no standardized controls, e.g. the clutch, brake and accelerator pedal were randomly located, according to the whim of the manufacturer. That is the case with today’s cranes and man-lifts. HMI defects plague modern systems because the regulators and designers have never had to use them. Bad HMI design is a topic which needs its own series of articles.

3. The Mechanics Of What Causes Human Accidents

Herbert Spencer was an observer of man’s social condition, he wrote in 1891 that: “The ultimate result of shielding men from the effects of folly, is to fill the world with fools.” Too many of today’s post-1980’s safety rules try to regulate against human error, without proper regard for how humans interface with systems. For example we know that, under controlled hazardous conditions, humans naturally do a good job of keeping themselves out of harm’s way. Outward Bounds character building programs put young people under a degree of perceived danger and stress, to draw upon their own resources to do things like perform tasks at great heights or take a small boat out of sight of land.

The petrochemical industry does this when they send nerdish control room operators for fire fighting training. The idea here is, that petrochemical fires are best controlled within the first five minutes of breaking out. Often, the only people available in a big automated plant to quickly fight a fire are those in the control room. The training itself exposes the participants to great danger, but shows them how to work in a team to use the equipment at hand, to keep control of a potentially dangerous situation.

We also know that people hurt themselves when they lose concentration, either through fear, fatigue, or information overload (which includes distraction). Too many safety rules talk down to people as if they were idiots, creating a boring work environment where boredom induced fatigue too easily sets in. Excessive nanny state safety rules provide conditions where humans cannot use their own initiative to do work and look after their own safety.

One result of over-regulation’s attempts to “shield men from the effects of folly” is a sullen resentment that people cannot use their own initiative to do work. Over regulation has made far too many modern work tasks into boring, repetitive and soul destroying prison sentences for the users.

1 comment to Three Sensible Safety Trends We Would Like To See

There were 15 good quality comments about this post, made at: oilpro.com:

Comments (15)

Larry Ginther · Jan 28 · Reply · Unlike · 5
“Excessive nanny state safety rules provide conditions where humans cannot use their own initiative to do work and look after their own safety.” This statement speaks volumes to me. I previously worked for a multi-national oil company that liked to proceduralize everything. Every time there was an incident, instead of holding someone accountable for their actions they wrote a new procedure. Before long it took two 4″ ring binder to hold their safety manual, that is excluding Environmental, Emergency Response or Asset Integrity programs. The running joke on the floor became, “Check your brain at the gate. You won’t need it because there is a procedure for everything.” As a manager those types of comments scare the hell out of me. You want your employees engaged, thinking about the hazards and thinking of how to mitigate those hazards for each different scenario. I have since develop the safety training manual/program for two smaller (mid-size) companies. They have both been less than 200 pages. They lay out the basic rules of engagement as defined by occupational health and provide enough material so employees understand the hazards and can properly do a hazard / risk mitigation assessment. Further to that these companies have nurtured a culture where people feel free to ask others to assist in these assessments when they are uncertain about a particular hazard. The message here is “don’t allow your employees to become mindless drones. Give them the training and the tools to think on their feet so that when one off situations arise they can develop plans to complete the job safely or respond to emergencies with a certain degree of confidence”.

Evan Jones · Jan 28 · Reply
This regulatory over-reaction to safety incidents needs to be properly examined, defined and given it’s own name. We are a culture of reductionist straight line thinkers in a world influenced by a bewildering array of subtle second and third order effects. Mandating a procedure in reaction to an incident, is a symptom of crude reductionist thinking. Following the 1997 IMF crisis which pauperized 40 million Indonesians, the reaction of government officials to an outbreak of hunger driven prostitution was to ban prostitutes.

Stephen Watkins · Jan 28 · Reply · Like
Larry Ginther,

I believe that you are right. One body can not “Protect a fool from himself” and our Safety Regularity Bodies are peopled by . . . . . . . “fools who can not only protect themselves but put working hands into trouble”.

Evan Jones · Jan 28 · Reply · 1
Rick Kaiser wrote:

There are “feedback loops” in all of these regulations .. Rick, you raise a good point, I think you mean there should be feedback loops. These deadly and useless OLRRS devices have been mandated for decades; FRBs for nearly 20 years. Any sign of any feedback? If a billion people have had their time wasted in post 9/11 air passenger airport security checks, which have yet to find even one terrorist, does that indicate a defect in our safety systems? Maybe we are all stupid sheep? Rick wrote: Talk to people, make changes. Yes, that looks like a good start, maybe the world needs local Sensible Safety User Groups who can highlight dysfunctional safety regulations?

Robert Mathes · Jan 28 · Reply · Like · 1
It is refreshing to see someone taking a stance with respect to over-regulation of work by well meaning people that unfortunately only see the work sites they regulate during a guided tour, and too many of them never having worked in the trade they pretend to regulate. Sensible Safety Rules can only be created from a deep understanding of the work being regulated and that understanding only comes with having performed personally the tasks with your own hands. Engineers are not allowed to get their hands dirty because of the fear that they might injure themselves, in addition to the stupid notion that manual work is below an engineer’s social standing. We all need to remember were does the profession of the Engineer come from: it is the use of ingenuity to solve practical hands on problems. Ergo, we get designs that lack practically or are devoid of common sense because these engineers have no notion what it takes to execute their designs. The list is almost endless, with over specialization having sown stupidity in the work place.

Michael Oakes · Jan 28 · Reply · Like · 1
There is a very basic rule which needs to be followed and I don’t understand why it is not followed. How can somebody who does not personally undertake a particular job/task tell somebody who does it every day how to do it! The people at the sharp end (the workers) should always be involved in the formulation of any procedure as they know what the potential problems and pitfalls are. for instance the Plant maybe 30 years old and not work as it did when it was first commissioned the process workers will know how to work around the shortfalls but unfortunately they will be outwith the company procedures. The procedures need to change to keep up with whatever developments are necessary but it requires the management to listen and take heed of the wealth of knowledge on their own doorstep! I don’t know if it is arrogance on the part of the Engineers or just ignorance why the workforce are not involved at the beginning of formulating any procedure or RA for that matter. Along with that they are more likely to follow it if they feel part of the process, a sense of ownership if you like..

Lar Reitz · Jan 28 · Reply · Like · 1
Evan you got it figured out. You have learned what works and what is computer generated bull exhaust based on perfect performance. That stuff gets the MBA’s from the home office hurt and doesn’t happen in the real world. Newbies take heed.

Jimmy Clem · Feb 3 · Reply · Like · 1
Unless the rabbis of the safety world have been on a vessel with a breached hull and donned the life vest for a night of adventure in the shark infested deep, it is likely their proposed solutions are theoretical in nature and abstract in practicality. Even young and inexperienced men learn with passionate enthusiasm in a dangerous environment. If stupid is as stupid does, then smart is as smart does. No politician, no safety council, no insurance lobbyist, and no Philadelphia lawyer can trump a man’s personal survival accountability to himself. Rock on Evan.

Jill Friedman · Jan 28 · Reply · Like
Excellent article! I couldn’t agree more!! This needs to be put in front of the face of every regulator out there (but of course, they’ll ignore it cause they all know better than us stupid sailors). It’s their job to save us from ourselves (sarcasm).

Rick Kaiser · Jan 28 · Reply · Like
I strongly believe that every oil field / rig / platform / refinery worker has the right to perform their jobs in a safe work environment and at the end of the day come home safely to their families. We work at good-paying jobs that come with the accompanying high risks of boring holes deep into the earth, transporting volatile products, and working around processes with high temperatures and pressures. Oil field and industrial safety have come a long way in the past 100 years when lost hearing, fingers and lives were far more common. While we groan about some of the more questionable and onerous regulations, we also take for granted so many more of the others that protect us daily; PPE, railings, lock-out/tag-out, hot work permits, automation, PSM, etc.

You have identified specific instances and bring up good points on how some safety systems do not work under actual field conditions, and they also endanger other people in the process. Regulations may be enforceable, but they are not static. They are designed to change as the technology and environments we work in change. There are “feedback loops” in all of these regulations, and I, like you, encourage EVERYONE in our business, to become involved in maintaining and improving the safety of our workplaces. Document and report these deficiencies to the regulating authorities. Become involved in your on-site safety processes. If you see at-risk work habits and unsafe job sites, do something positive about it. Talk to people, make changes. Things you do today will save a life tomorrow; maybe your own.

Derek Harris · Jan 28 · Reply · Like
Derek W. Harris. A very good article, I completely agree with all the subjects. The lifeboat release system is a big issue as some are complicated to reset unless properly trained. Trying to hook up a lifeboat in open water is a very dangerous process and although some authorities and plan maintenance systems require lifeboats to be launched every 3 or 6 months is not always feasible especially on semis and jackups. I never lower any boats with personnel aboard so requires them to board from another FRC, then disconnected tested and reconnect. The latter is very dangerous trying to connect up and reteave the boat. There is a big risk if the releasing gear is not reset properly also. On semi’s and jack ups there are not always AB’s and experienced seaman to do this task, just Roustabouts. I was pleased to see and use free fall lifeboats, no wires or falls to deal with once released. This makes big sense to me , however, I be leave they will be banned in the future. Also many lifeboats are designed to carry personnel crammed into the boats, in cold climates with a survival suit and life jacket , ok for small crew like Filipino’s about 50-60 kgs but most Westerners are 100+ kgs. The free fall type have a dedicated seat for each person. I have seen the Cruise ships doing drills in harbors and its usually very disorganized and confused. Imagine trying to evacuate 5000 persons, I worked on a passenger ferry licence to carry 2000 passengers using Radial arm davits and manila rope falls lowering was by hand, this was in the 1970’s. Approved by Canadian and USA Coast Guard. Trying to launch lifeboats in rough weather is very hazardous and dangerous even if successful. I would like to see some other method of evacuating personnel, it can be done and there is technology waiting to be developed. As far as Safety in the work place, a person will work safe if he uses common sense and respects safety, there are always personnel whom do not apply the latter. Unfortunately some times they are protected by unions and or regulations. I have worked on ships and rigs, the former are much more conscious of safety and better trained. On the rigs the crews are not as well trained in seamanship, fire and lifeboat training, this is a fact. Thanks for a great article Derek

Mark Van Velzor · Jan 28 · Reply · Like
How do you set the requirement for safety and at what threshold level?

Are you going to use some value/cost analysis?

If so on what basis.

Are you going to take the threshold as one life is to high a price or do you permit so many people to die over a certain period of time?

Or if no deaths are acceptable is the loss of x limbs per y years acceptable or ar no limbs permitted to be expended but m digits per n years acceptable?

Or is it p laundry moments per q years.

Or do we leave it to litigation for death, dismemberment and incapacity due to injury?

The goal of most has been to eliminate deaths; hence, the overreach according to some.

I agree that if a regulation is not decreasing the death or injury rate at all, that it needs to be revisited.

Keep in mind like most everything in life if something cost you money even if there is no demonstrated benefit to me, my human nature is the want a decreased risk as long as others pay for it even if the risk is miniscule or non existent, perception sometimes over rides logic and rationality.

With that being said, the above threshold levels need to be addressed as does the effectiveness of the means and methods used.

Setting threshold levels is a bit morbid as they say and provides vital fodder for litigators in the civil actions that are intiated when injuries and death follow.

Evan Jones · Feb 4 · Reply
Mark asks: Q: >How do you set the requirement for safety and at what threshold level? >Are you going to use some value/cost analysis? A: Yes sure, let’s just set the threshold value at 1 human life, meaning that any safety requirement that ends 1 more human life than it prevents, should be instantly withdrawn for further review. That’s the reasoning used by the aviation industry to sometimes ground aircraft.